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Internal Audit and Counter Fraud Summary of Activities

Argyll and Bute Council · 20 December 2022
Back to Audit and Scrutiny Committee — 20 December 2022 and its agenda

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ARGYLL AND BUTE COUNCIL  AUDIT & SCRUTINY COMMITTEE   
FINANCIAL SERVICES  20 DECEMBER 2022  
INTERNAL AUDIT  AND COUNTER FRAUD SUMMARY OF ACTIVITIES 
1. SUMMARY  
1.1 The objective of the report is to provide the Audit and Scrutiny Committee (the
Committee) with a summary of Internal Audit activity and progress during
quarter three of 2022/23.  
1.2 Core activities together with a progress update statement are shown below: 
 2022/23 Audit Plan progress: On track subject to available resources
being in place for the full period of the approved plan and that two reviews
are postponed until 2023-24 for organisational reasons. 
 Individual Audits undertaken: Nine audits have been completed during
the period. Two audit has been assessed as providing high assurance,
seven as substantial assurance, none reasonable assurance and none as
limited assurance. (HSCP Audits provided for information only). 
 Counter Fraud: The Counter Fraud team is continuing to rebill council tax
accounts and recovery of funds is underway.  All other aspects and referrals
are being considered, investigated and evaluated and the Counter Fraud
Team remain vigilant to protect our public purse. 
 Continuous Monitoring Programme Testing: A number of auditable units
are subject to continuous testing. Two issues have been identified in quarter
two and management have responded to previous quarter notifications. 
 Performance indicators: Current status is green / on track. 
2. RECOMMENDATIONS  
2.1 To review and endorse the Summary of Activities report.  
3. DETAIL  
3.1 Nine audits have been completed since the previous Committee in
September 2022. Three audits are currently in progress and will be to follow. 
Audits Completed 
 Performance Management (HSCP) – For Information Only
 Directions (HSCP) - For Information Only
 Commissioning (HSCP) - For Information Only
 Heritage Assets
 Externally Funded Projects

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 Early Years – Covid Funding
 Private Sector Grants & Housing Adaptations
 Oban Airport
 Campbeltown Aqualibrium   
Audits in Progress
reported to a future meeting of the Committee 
 Procurement
 Events Management
 Management of Debt & Debt Recovery
 Client Funds  
3.2 In addition to those already in progress indicative audits planned for Quarter 4
2022/23 are:  
3.3 2022/23 Audit Plan 
 Customer Service Centre
 Payroll
 Building Standards
 Cyber Security
 Burial Records
 Counselling in Schools
 Equality and Socio-Economic Impact Assessment  
3.4 The audit of Learning and Physical Disability Care Packages has been
postponed until April 2023, this review will be now cover a much wider remit
and include governance and management and will be included in the 2023-
24 internal audit plan. This approach has been deemed appropriate by the
relevant service and internal audit.   
Scrutiny  
3.5 Work has been completed on the 2021/22 scrutiny plan.  Scrutiny topics for the
2022/23 plan will cover consultations and a draft Terms of Reference has been
produced and the review team identified, the first meeting has been scheduled
in order to progress the review. This report will be reported back to a future
meeting of the Committee once it has been completed. Progress will also
shortly commence on residual follow up on the previous review on ‘Fly
Tipping’.     
Counter Fraud  
3.6 The CFT is progressing well with both team members fully CIPFA accredited
fraud investigators. Continued routine work is required to be able to accurately
track the full income recovered from the team’s work, however, based on the
amount of additional billing, even accounting for a degree of non-recovery, the
indications are that they are easily exceeding target. In addition they are
raising awareness of the Council’s zero tolerance to fraud and this will act as a
deterrent to fraud being perpetrated in the first place. Crucially, if no Counter
Fraud team had been in place then the reported instances of fraud would still
be taking place at a cost to the Council and public purse.

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3.7 The CFT have spent time on preparing ‘data uploads’ from the Council which
feed into the National Fraud Initiative (NFI) matching service, it is anticipated
that any matches will be provided to the team in January 2023 to allow work to
commence on following these up locally.   
Additional Updates from Quarter Two  
3.8 Staff continue to work from home and this has proved to be successful; where
on-site visits have been required due to the specific nature of the audit work to
be undertaken, these visits have occurred in accordance with any guidance
that was in place.  
3.9 The Public Sector Internal Audit Standards (PSIAS) require the Council’s
Chief Internal Auditor (CIA) to develop a Quality Assurance and
Improvement Programme (QAIP). The purpose of the QAIP is to enable the
evaluation of internal audit’s conformance to the PSIAS. The QAIP must
include annual internal self-assessments with a five yearly external
assessment, carried out by an independent assessor.  A programme of five
yearly reviews has been prepared by the Scottish Local Authorities Chief
Internal Auditors Group (SLACIAG) and these will be conducted by peer
review, Argyll and Bute Council has been scheduled for review in September
2022 by East Dunbartonshire Council.  This review has commenced and a
report will be submitted to a future meeting of this committee.  The annual
self-assessment is not required due to the external assessment taking place
and will resume in 2023 with a report submitted to this committee in
September 2023.     
Continuous Monitoring  
3.10 Our continuous monitoring programme is generally focused on transactional
type activity. Standard audit tests are applied which are relevant to each
auditable unit. Control design tests look at whether the controls in place
adequately address the potential risk event. There have been two new findings
within the quarter that require to be reported. 
Table 2: Continuous Monitoring Findings 
Auditable
Area
Areas Tested Issues Identified Management
comment / action
Payroll
Expenses
Expenses are
appropriately
supported by
receipts
Claims are still being
approved without the
appropriate paperwork. 
This has been
highlighted to Creditors
and HR who have then
passed onto Payroll.
Payroll
Expenses
Claims for
expenses
incurred
greater than 6
months are
authorised by
Executive
Director
Claims over 6 months
old are still being
approved without
appropriate
authorisation.
As above

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3.11 A follow up process is in place whereby management are advised of
continuous monitoring findings and, where appropriate, requested to take
remedial action.  There are currently no outstanding follow-up points arising
from previous testing.  Due to the volume of continuous monitoring tests
carried out the decision was made to report by exception only.     
National Reports  
3.12 A follow up process for national reports is in place whereby management are
advised of national reports published and asked to confirm what, if any, action
is planned as a result of the report.  Table 2 details the national reports issued
during quarter one 2022/23.  
Table 3: National Reports 
National
Report
Issued
To
Detail Management response/ Action
taken
The
National
Fraud
Initiative in
Scotland
2022
Counter
Fraud
Team
The overall level of
identified public sector
fraud and error in
Scotland has fallen
slightly, according to
the results of a
national counter-fraud
exercise.
The Council continues to
demonstrate commitment to
counter fraud including investment
of time and effort into the NFI by
participating in the 2023/24
exercise.  High-risk matches will
continue to be prioritised in
accordance with the guidance
provided, however, matches
provided as a result of the NFI
exercise have often been identified
and resolved by officers prior to
being made available for review on
the NFI application. 
The Audit and Scrutiny Committee
continue to be updated on counter
fraud activities including progress
with the NFI exercise by way of
quarterly reports and an annual
report.  The self-appraisal checklist
has been completed and is
submitted as a separate paper to
this Committee for review.   
The Council’s Counter Fraud
Team have had a very successful
first two years and as a result no
specific areas for improvement
have been identified by local
auditors.

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Best Value
Assurance
Report
Shetland
Islands
Council
Chief
Executive
Shetland Islands’
leaders need to
increase their pace
and focus to deliver
urgent change.  The
Accounts Commission
is not confident the
Council is able to
show it is financially
sustainable.
This report was considered by
SMT 27 September where it was
agreed that no actions are
required.
Scotland’s
councils’
approach
to
addressing
climate
change
Executive
Director
Douglas
Hendry
Scotland’s councils
must put tackling
climate change at the
heart of decision-
making.
Councils have a
critical role in helping
Scotland achieve its
national climate
change goals, in
particular reducing
CO2 emissions and
adapting and
transforming services. 
Climate change must
be central and integral
to all council activity.
This report will be considered, in
the first instance, by the Climate
Change Board (CCB).  The CCB
will identify any steps which
require to be taken by the
Council.
Tackling
child
poverty
Chief
Officer
HSCP
Longer-term joint
planning is needed to
address child poverty
in Scotland, which has
increased since
targets were set in
2017.
Actions to tackle child poverty are
ongoing and co-ordinated via the
Argyll & Bute Child Poverty Action
Group. 
A report will be prepared to
provide information on local
actions and the Child Poverty
Action Plan Review 2021-22.
Best Value
Assurance
Report
Comhairle
nan Eilean
Siar
Chief
Executive
Councillors at
Comhairle nan Eilean
Siar must provide
leadership and clear
priorities if the
organisation is to
improve public
services and address
significant financial
and workforce
challenges.
This report was considered by
SMT in October where it was
agreed that the content was
useful but no actions are required.

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National Fraud Initiative (NFI)  
3.14 NFI data matching involves comparing computer records held by one body
against other computer records held by the same or another body to identify
potentially fraudulent claims and payments to be identified. Note though that
the inclusion of personal data within a data matching exercise does not mean
that any specific individual is under suspicion. Where a match is found it
indicates that there may be an inconsistency which requires further
investigation. No assumption can be made as to whether there is fraud, error
or other explanation until an investigation is carried out.  A reminder process is
in place to ensure that matches are reviewed on a timely basis.  
3.15 The most recent cycle of NFI activity has now been concluded with the new
data set due to be available in January 2023. Therefore the usual table update
on matches progressed has been removed as there has been limited activity
since the last committee.  The table updating the committee on matches
progressed will be reinstated from the March 2023 meeting of the Committee
onwards.   
Internal Audit Development  
3.16 The table below details progress against the action points in our Internal Audit
development plan.  All items have been addressed and no additional items
have been added in quarter one.  
Table 4: Internal Audit Development Key Actions: 
Area For
Improvement
Agreed Action Progress
Update
Timescale 
Nothing outstanding.   
3.17 Internal Audit scorecard data is available on pyramid. The indicators reported
are aligned to those for internal audit in the Financial Services service plan.  All
indicators are shown as currently being on track.

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Table 5: Internal Audit Team Scorecard  
Internal Audit Team Scorecard 2022– 23 – FQ2 22/23 (as at September 2022)
BO115 We Are Efficient And Cost Effective    
Internal Audit Level of Satisfaction
Actual  97% G 
Target 80%
Review of Strategic Risk register
Status On Track G 
Target On Track
Percentage of audit plan completed
Status 100% G 
Target 100%
Percentage of audit recommendations accepted by
management
Actual  100%
G
Target 100% 
4 CONCLUSION  
4.1 The 2022/23 audit plan is on track and the Counter Fraud Team is continuing
with visits and pro-active work throughout Argyll and Bute.  
5 IMPLICATIONS
5.1 Policy - Internal Audit continues to adopt a risk based approach to activity
5.2 Financial –None
5.3 Legal –None
5.4 HR – None
5.5 Fairer Scotland Duty – None
5.5.1 Equalities – None
5.5.2 Socio-Economic Duty – None
5.5.3 Islands Duty – None
5.6 Climate Change – None 
5.7 Risk – None
5.8 Customer Service – None 
For further information please contact Internal Audit (01546 604108)
Paul Macaskill
Chief Internal Auditor
20 December 2022